Law School Case Brief
Pierce v. Soc'y of Sisters - 268 U.S. 510, 45 S. Ct. 571 (1925)
Legislation may not unreasonably interfere with the liberty of parents and guardians to direct the upbringing and education of children under their control. Rights guaranteed by the U.S. Constitution may not be abridged by legislation which has no reasonable relation to some purpose within the competency of the state.
Two private primary schools, Society of Sisters and Hill Military Academy filed actions against the Governor of Oregon and other state officials (“appellants”) challenging the constitutionality of the Compulsory Education Act (Act) under U.S. Const. amend. XIV and seeking to enjoin its enforcement. The Act mandated that all normal children aged 8 to 16 years old must attend public school. The schools asserted that their enrollments were declining as a result of the Act. The district court entered an order enjoining the State from enforcing the Act and the State sought review in consolidated appeals. It asserted that since the schools were corporations, it had no amend. XIV rights.
Did the Compulsory Education Act violate U.S. Const. amend. XIV?
The Court ruled that the inevitable practical result of enforcing the Act was the destruction of the primary schools and perhaps all other private primary schools for normal children within the state. According to the Court, the Act unreasonably interfered with the liberty of parents and guardians to direct the upbringing and education of their children. The Court further held that although the schools were corporations, they could claim constitutional protection for their business and property. The Court noted that the corporations sought protection against a present and real threat of injury from the arbitrary, unreasonable, and unlawful interference with their patrons and injunctive relief was proper.
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